Jin Xiong - Page 12

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          under section 280F, and strict substantiation is therefore                  
          required.  Sec. 274(d).  No deduction is allowed for any travel             
          or transportation expense unless the taxpayer substantiates by              
          adequate records or by sufficient evidence corroborating the                
          taxpayer’s own statement the amount of the expense, the mileage             
          for each business use of the automobile and the total mileage for           
          all use of the automobile during the taxable period, the date of            
          the business use, and the business purpose for the use.  Sec.               
          1.274-5T(b)(6), Temporary Income Tax Regs., 50 Fed. Reg. 46016              
          (Nov. 6, 1985).  Adequate records include the maintenance of an             
          account book, diary, log, statement of expense, trip sheets,                
          and/or other documentary evidence, which, in combination, are               
          sufficient to establish each element of expenditure or use.  Sec.           
          1.274-5T(c)(2)(i), Temporary Income Tax Regs., 50 Fed. Reg. 46017           
          (Nov. 6, 1985).                                                             
               Taxpayers may use a standard mileage rate established by the           
          Internal Revenue Service in lieu of substantiating the actual               
          amount of the expenditure.  See sec. 1.274-5(j)(2), Income Tax              
          Regs.  The standard mileage rate is generally multiplied by the             
          number of business miles traveled.  See Rev. Proc. 2002-61, 2002-           
          2 C.B. 616 (in effect for transportation expenses incurred during           
          2003).  The use of the standard mileage rate establishes only the           
          amount deemed expended with respect to the business use of a                
          passenger automobile.  Sec. 1.274-5(j)(2), Income Tax Regs.  The            

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